Tips for Form R Reports, Due July 1

Now that 2015 is well underway, designated facilities under the Toxic Release Inventory (TRI), or "Form R," reporting requirements at 40 CFR 372 should start preparing to submit 2014 data to US EPA by the July 1 deadline.

Who Must Report?

Facilities that meet all of the following criteria are considered "designated facilities" and must submit a Form R to EPA:

1. Businesses assigned to SIC Major Groups 10, 12, and 20–39; SIC Industry Groups 4911, 4931, 4939, 4953, 5169, 5171, and 7389; or that are Federal agencies; and
2. Employing 10 or more full-time employees (or the equivalent hours worked by part-time and/or contract employees); and
3. 3. Having manufactured (including imported), processed, or used any toxic chemical listed at 40 CFR 372.65.

           [40 CFR 372.1]


The trigger quantities for reporting are assigned on a chemical-by-chemical basis (not cumulative of all chemicals), as follows:

• The facility manufactured, imported, or processed: 25,000 lbs. or more during 2014.
• The facility otherwise used 10,000 lbs. or more during 2014.

Chemicals of Special Concern

Thresholds are also ascribed to "chemicals of special concern," or chemicals that are known to be persistent, bioaccumulative, and toxic (PBTs), as listed at 40 CFR 372.28. These thresholds are significantly lower due to the heightened potential for lasting damage to human health or the environment. [40 CFR 372.25, 372.28]

Category or Chemical Names	Reporting Threshold
Dioxin and Dioxin-like Compounds[1]	0.1 g
Benzo(g,h,i)perylene	10 lbs.
Chlordane	10 lbs.
Heptachlor	10 lbs.
Hexachlorobenzene	10 lbs.
Isodrin	10 lbs.
Lead Compounds[1]	10 lbs.
Mercury Compounds[1]	10 lbs.
Mercury	10 lbs.
Octachlorostyrene	10 lbs.
Pentachlorobenzene	10 lbs.
Polychlorinated biphenyl (PCBs)	10 lbs.
Toxaphene	10 lbs.
Aldrin	100 lbs.
Lead [2]	100 lbs.
Methoxychlor	100 lbs.
Pendimethalin	100 lbs.
Polycyclic Aromatic Compounds[1]	100 lbs.
Tetrabromobisphenol A	100 lbs.
Trifluralin	100 lbs.

[1] This category only includes those chemicals listed in 40 CFR 372.28(a)(2).
[2] This lower threshold for lead does not apply to lead when contained in a stainless steel, brass, or bronze alloy.

About TRI Reporting

The Toxic Release Inventory is meant to account for the various ways that toxic chemicals "enter the environment," including amounts released to the air or water and those treated, disposed of, or recycled on site or sent away form treatment, disposal, or recycling.

E-reporting Is Now Mandatory

As of January 14, 2014, EPA will no longer accept paper submissions of Form R. Facilities must submit their completed TRI, or "Form R," report electronically.

The TRI-ME (Toxic Release Inventory Made Easy) Web application works through the EPA's Central Data Exchange (CDX). Individuals reporting through the CDX must go through a registration process, and that process must be completed before attempting to submit the Form R using the TRI-ME portal. More information about TRI-ME and CDX can be found here.

Be confident you're ready to meet all of EPA's regulatory requirements for air, water, chemicals, and more at the interactive Complete Environmental Regulations Workshop, presented nationwide. If you're responsible for ensuring site compliance with many complex programs—from the Clean Air and Clean Water Acts to TSCA, FIFRA, EPCRA, and more—this workshop will help you identify the requirements that apply to your facility and make decisions that put your environmental team in a position to succeed.

Tags: EPA, reporting and recordkeeping